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<br />documentation. Please provide the required information or omit the language from the <br />permit application. <br />76. Also noted on pa e 7 is that SCC will request comments on the postmirung land use from <br />landowners and local government agencies, and will forwazd those comments to the <br />Division. Please send copies of comments from all landowners and agencies as soon as <br />they become available, as the Division cannot issue a permit for the operation without <br />them. <br />77. SCC is proposing to use extended reference areas. These aze not defined as to location. <br />SCC does comm>t to managing these extended reference areas the same as the reclaimed <br />azea. The Division needs assurance that these extended reference azeas will not be <br />disturbed. <br />a. Please provide a designation of the location of the "extended" reference azeas on <br />permit application exhibits. <br />b. Please demonstrate that the reference areas represent the area to be disturbed as <br />per Rule 4.15.7(3)(b). <br />78. The Division is in agreement with the concept of the concentrated shrub azeas. However, <br />the Division considers a woody plant density of 1000 stems per acre on 5% of the <br />reclaimed area (shrub concentratJOn areas) to be on the low side. To put this into <br />pperspective, this would impose a standazd of 1 shrub every four squaze meters on only <br />20 acres of the 404 affected acres during the fast permit term. The overall reclaimed <br />azea standard of 250 stems per acre translates to 1 shrub per every 17 squaze meters. <br />Due to the fact that one of the proposed postmining land uses will be for wildlife habitat <br />the Division questions whether the ]000 stems per acre within the clamped areas will be <br />adequate for wildlife utilization. The Colorado Division of Wildlife has not yet <br />commented on these density levels. Please propose a denser standard for the <br />concentrated shrub plot areas, or provide additional information to justify this level of <br />shrub density within the concentrated shrub azeas. <br />79. While the Division recognizes that Seneca Coal Company is roposing progressive <br />attempts at reestablishing the woody species, we are also concerned about failure of these <br />concentrated azeas. If these concentrated shrub plots should fail Seneca Coal Company <br />needs to be awaze that there will have to be other attempts at reestablishment. <br />80. DMG recognizes that SCC has made efforts in reestablishment of aspen in other mine <br />permit azeas with discouraging results. Page 21 discusses SCCs reasons for not including <br />aspen in the reclaimed area. Due to the significant extent of aspen community proposed <br />to be affected during the first permit term (54.3 acres, approxunately 12% of potential <br />disturbed area), DMG believes attempts to reestablish some aspen within the reclaimed <br />area are warranted. Althouggh aspen are included in Table 22-8 Planting List 2 as <br />"substitute" species and page 21 states aspen may be used "if available", DMG reciuests <br />that Seneca Coal Company commit to inclusion of this species in the planting hst or <br />provide additional information justifying its exclusion. <br />81. SCC has proposed to use an acreage weighted calculation of herbaceous vegetation cover <br />in the reference azeas, and then factor by 3. The Division considers this proposal <br />adequate but wants to remind SCC that this cover will still have to meet the requvement <br />of being adequate to control erosion as per Rule 4.15.1(2)(b). <br />82. Exhibit 10-1, Vegetation, appears to have two typographical errors. Mountain Brush is <br />M. Altavilla and G. Wendt 14 January 23, 1995 <br />